Privacy Policy

Effective date: May 4, 2026 · Controller: Clara Applied Intelligence GmbH (“Clara”, “we”).

1. Scope

This Privacy Policy describes how we collect, use, disclose, and safeguard personal data when you visit apps-cc.pro, use the Clara product, communicate with us, or interact with our marketing. If you use Clara on behalf of a company, that company may be an independent controller for employee data it uploads; this policy explains Clara’s role and your rights as an individual user.

2. Data we process

• Account & contact data: name, email, company, billing address, VAT number, authentication identifiers.
• Service content: text, files, and prompts you submit to Clara to generate brand strategy outputs.
• Technical data: IP address, device type, browser, approximate location derived from IP, timestamps, and diagnostic logs.
• Support & sales communications: messages you send to us, including attachments.
• Marketing preferences: subscription choices and engagement metrics for emails you receive from us.

3. Purposes and legal bases (GDPR)

• Contract (Art. 6(1)(b)): providing Clara, processing payments, customer support.
• Legitimate interests (Art. 6(1)(f)): securing the service, abuse prevention, analytics to improve UX, direct B2B marketing where permitted.
• Consent (Art. 6(1)(a)): non-essential cookies and certain marketing where required.
• Legal obligation (Art. 6(1)(c)): tax, accounting, and regulatory compliance.

4. AI processing

Clara uses machine learning models to analyze your inputs and generate recommendations. Depending on configuration, processing may involve subprocessors in the EU, UK, or United States with appropriate safeguards (including Standard Contractual Clauses where applicable). We do not sell personal data. We do not use your confidential workspace content to train foundation models unless you opt in via a separate agreement.

5. Retention

We retain account data for the life of the contract plus a statutory period (typically 6–10 years for invoices). Workspace content is retained according to your plan controls and deletion requests. Backups may persist for a limited technical window after deletion.

6. Sharing

We share data with payment processors, hosting providers, email delivery services, analytics vendors (where consented), and professional advisers as needed. A current subprocessor list is available upon request to [email protected].

7. International transfers

If data is transferred outside the European Economic Area, we implement appropriate safeguards described in our Data Processing Agreement (DPA) for business customers.

8. Security

We apply industry-standard technical and organizational measures, including encryption in transit, access controls, logging, and periodic reviews. No method of transmission is 100% secure; please use strong passwords and SSO where available.

9. Your rights

Depending on jurisdiction, you may have rights to access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. You may lodge a complaint with a supervisory authority. To exercise rights, contact [email protected]. We will verify requests to prevent unauthorized disclosure.

10. Children

Clara is not directed to children under 16, and we do not knowingly collect their personal data.

11. Changes

We may update this policy to reflect product, legal, or regulatory changes. Material updates will be communicated via email or in-product notice. Continued use after the effective date constitutes acceptance where permitted by law.

12. Contact

Clara Applied Intelligence GmbH
Torstraße 19, 10119 Berlin, Germany
Email: [email protected]